Response to cP on comprehensive ITS for financial institutions public disclosure

Question 24: Are the instructions, tables and templates clear to the respondents? Further information is needed on LCR delta. It would be useful to have an indication of the criteria to determine the threshold above which an explanation of the delta is worth to be disclosed by the single bank.

It is not clear the mapping between EU LIQ2 for disclosure on NSFR vs drafted templates C.80-C.81 for reporting on NSFR i.e. it looks like EU LIQ2 is based on NSFR QIS template. Specifically, the information in row 23 is already included in row 21. Should this be excluded it in order to avoid double counting?

Question 62: Regarding template EU MR2-B (flow of RWAs), do respondents agree that the drivers included for the variations of the RWEA are a good reflection of the main factors driving these variations or is there any additional relevant driver that should be added? Regarding template EU MR2-B, we agree with the drivers included for the variation of the RWEA are a good reflection of the main factors driving these variations.

However, we do not agree with the explanation of row {1a/b} and {8a/b} of Template EU MR2-B in Annex 34. According to the instructions, in case of RWA/own funds requirements are calculated as 60-day average (VaR/SVaR)/12-week average or floor measure (IRC/CRM) and not as RWA/own funds requirement at the end of period. Rows 2,3,4,5,6,7 reconcile the value in row 1b and 8a, but – since RWA/own funds requirements are calculated as average over the time period – the reconciliation should be performed with the value in row 1 and 8.

Question 66: Are the instructions, tables and templates clear to the respondents? Please refer to the enclosed document as well as for general remarks on this particular section and on the consultation as a whole.

Question 67: Do the respondents identify any discrepancies between these templates and instructions and the calculation of the requirements set out in the underlying regulation? Concerning possible discrepancies between templates and instructions and the calculation of the requirements set out in the underlying regulation, we share the proposal of summary tables on remuneration policies, with a detail of the items to be indicated, in order to be able to achieve a homogeneous comparison at European level of qualitative and quantitative information on the topic.

However, bearing in mind that the consultation is aimed at clarifying the scope of the Article 450, in which it is envisaged that "Institutions shall disclose the following information regarding their remuneration policy and practices for those categories of staff whose professional activities have a material impact on institutions' risk profile", table REM5 regarding “Information on remuneration for all staff” does not represent a fulfilment contained in the EU legislation, and as such an option should be considered regarding the disclosure of this information. Therefore, each company should be able to assess the appropriateness of such public disclosure.

As for the granularity of the proposed information, we share the disaggregation in the business areas currently used for the purposes of the benchmarking exercise carried out pursuant to the EBA 2014/08 "Guidelines on the remuneration benchmarking exercise", although it is considered appropriate to provide for a proportionality in the application of the discipline according to the company size, to avoid that small companies, required to compile the REM5 Table, may have to face privacy problems due to the limited number of subjects in the individual business areas proposed.

In relation to the quantitative reporting tables of the identified staff (REM1 and REM2), it is requested to foresee the possibility of disaggregating the information based on the same areas of activity proposed in the REM5 table, where the companies deem it appropriate. Specifically, for banks in the scope of benchmarking at European and / or national level - which already fill in the tables relating to the identified staff the breakdown in the business areas proposed in table REM5 - we ask for the same accounting report, in order to avoid further management burdens and to provide a consistent market picture.

It is hoped that the existing information will be rationalized, limiting the already heavy reporting costs on credit companies.

Question 68: Do the respondents agree that the new draft ITS fits the purpose of the underlying regulation? We do not completely agree that the new draft ITS fits the purpose of the underlying regulation for the reasons indicated above.